Religious slaughter – consultation on labelling scheme

Soon-to-close consultation by industry body

The Agriculture and Horticulture Development Board (AHDB), the statutory levy board representing farmers and growers, is consulting on the introduction of a new Halal Quality Standard Mark for all sheepmeat; as part of this scheme, the AHDB is proposing a new labelling system to indicate the method of slaughter used. However, the labels are not intuitively obvious and the wording “stun/with pre-stunning” will not be used in the primary branding of either mark.

Agriculture and Horticulture Development Board (AHDB)

The AHDB is an executive non-departmental public body (NDPB) sponsored by the Department for Environment, Food & Rural Affairs. It was established in 2008 by the Agriculture and Horticulture Development Board Order 2008 SI 576 under the provisions of the Natural Environment and Rural Communities Act 2006. In accordance with section 97(8)(a) of the Act, a draft of the Order was approved by a resolution of each House of Parliament.

The functions of the AHDB are specified in Article 3 and the Schedule to the Order, viz. (a) increasing efficiency or productivity in the industry; (b) improving marketing in the industry; (c) improving or developing services that the industry provides or could provide to the community; and (d) improving the ways in which the industry contributes to sustainable development. Article 6 states that the Board “must impose a levy to enable it to provide services for each industry covered by this Order, and Schedule 3 has effect”.

Background

The AHDB states [emphasis added]:

“The halal market remains a key area of focus for the AHDB Beef & Lamb trade marketing team. With sheepmeat being the primary protein of choice for the 2.7 million Muslim consumers in this country the value of this market cannot be underestimated. As part of our commitment to this sector, AHDB Beef & Lamb has undertaken a number of projects that aim to further develop the supply chain and aid the promotion of domestically produced halal sheep meat”,

“An eight-week consultation is being launched to assess industry opinion on a quality assurance scheme for halal meat”.

Consultation

The AHDB has given details of its proposals for the Quality Standard Mark for Halal Sheepmeat:

“the proposals, which would see on-pack labelling signposting whether the meat has come through an assured route, in order to help customers choose products on shelves. The consultation will establish whether there is support from the industry to progress the scheme”.

[The specialized nature of the consultation was such that we only picked it up very recently via Twitter]

The consultation response-sheet, available as a PDF or a Word file, provides for responses from a range of interested parties: Producer; Abattoir; Cutting Plant; Retailer (large or independent); Foodservice Operator; Islamic Scholar; Certifier; Consumer; and  Other. Completed forms are to be returned to halal@ahdb.org.uk or posted to Awal Fuseini, Halal Sector Manager, AHDB Beef & Lamb, Stoneleigh Park, Kenilworth, CV8 2TL, by 30th August 2017.

Comment

Coming from an NDPB, this is not a Government consultation per se. The consultation is industry-focused, directed at maximizing the opportunities within the halal market, which is consistent with the statutory functions of the AHDB, supra. Nevertheless, certain aspects of the proposed scheme are likely to draw the attention of consumer, religious, animal rights and other groups. Humanists UK has expressed particular concern with the marketing aspects of the scheme, viz. [our emphasis]

“As part of this proposal, halal sheepmeat will carry one of two marks to indicate whether pre-stunning or ‘traditional’ (where the animal is fully conscious at the point of slaughter) methods are used. However, these labels are nearly identical and neither actually indicates whether pre-stunning has taken place. The former [RHS, below] only contains the word ‘Halal Assured’ with a tick symbol and the latter [LHS] has the words ‘Halal Assured’ with the word ‘halal’ repeated in Arabic script.

The consultation document suggests ‘the wording “stun/with pre-stunning” will not be used in the primary branding of either mark’ making it difficult to determine what the label is intended to indicate. Humanists UK believes that if religious exemptions to slaughter laws are to continue to exist, at the least consumers should be able to make an informed choice about whether to purchase it or not. The best way to achieve this is to have a clear, easily and widely understood labelling system”.

As Frank pointed out in his comment to Lords debate “religious slaughter” – yet again

“Halal and kosher slaughter are part of the freedom of religion protected by Article 9(1): and it’s difficult to see how banning them outright could fall within the ambit of Article 9(2) – though in Cha’are Shalom Ve Tsedek v France [2000] ECHR 351 a majority of the Grand Chamber held that there was no obligation on France to permit ‘glatt kosher‘ slaughter so long as ultra-Orthodox Jews could obtain supplies from elsewhere.

If there’s a ‘freedom of others’ involved in all this, it’s presumably the freedom on conscientious grounds not to eat meat from animals that have not been pre-stunned before slaughter. My own view is that the Article 9-compliant approach to ensuring that freedom is a rigorous labelling regime so that people can see exactly what they’re buying.

We suspect that many will agree with this sentiment. However, the remaining time for raising concerns is very short.

Footnotes

1. “Sheepmeat” is a term of art, not a typo.

2. The Humanists UK website, (but not the proforma response) refers to compulsory labelling for religious slaughter. The mandatory element relates to the criteria laid down by NDPB for bodies using the labelling scheme, which itself is not obligatory (although it may have some commercial value). However, under Article 25(1) of the Order, it is an offence knowingly to provide false or misleading information relating to the requirements of the Order to the Agriculture and Horticulture Development Board or a subsidiary company.

3. Humanists UK has produced a model response for its supporters. It is not unknown for public affairs professionals “caught short” on submission dates, to use that of another organization and modify it to their own requirements.

Cite this article as: David Pocklington, "Religious slaughter – consultation on labelling scheme" in Law & Religion UK, 29 August 2017, https://lawandreligionuk.com/2017/08/29/religious-slaughter-consultation-on-labelling-scheme/

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